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Professions on the Radar By Milena Radoman

To effectively combat money laundering and deprive criminals of ill-gotten gains, states rely on the
vigilance of professionals.

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Bankers, insurers, investment advisors, effect that this generates.” However, it is not administration of legal persons, legal entities
lawyers, notaries, bailiffs, auditors, chartered easy to change the situation. “The new texts or trusts, in favour of third parties
accountants, auctioneers: over time, the list of add additional obligations and administrative - gaming houses and all gambling service
professions subject to the obligation to report procedures to 1,300 subject professions and providers
transactions they suspect could be the proceeds associations. These commercial companies, - bureaux de change
of crime or may participate in the financing of mostly made up of less than 10 people, do not - real estate agents and property dealers
terrorism has lengthened. Because dirty money have the human resources to understand what - auditors and tax advisors
can be laundered by purchasing expensive is expected so quickly. Culturally, Monaco is - legal advisors, only when they participate,
goods such as luxury cars, boats, jewellery, not ready to open registers, to control traders in the name of and on behalf of their client,
works of art or by gambling at a casino, non- who have been selling high-value goods for in any financial or real estate transaction
financial professions have also been added 40 years without asking for an identity card, - surveillance, protection and cash transport
to the traditional financial sector professions. who sell jewellery worth several million euros services
To counter this threat, professionals must be to people whom they have known personally - traders and persons dealing in goods, only to
proactive, with the designation of managers, for years – it cannot happen overnight! I see the extent that the value of the transaction
training, implementation of internal procedures, professionals every day (jewellers, estate or a series of related transactions is settled
activity reports assessing the risk and, agents, art dealers and others) and some do in cash for an amount equal to or greater
above all, vigilance towards customers with not understand what is happening to them than €10,000
suspicious transaction reports, if needed; and that they need to investigate their clients”, - traders and people who negotiate or act as
because according to Moneyval, in this area, confides a compliance professional. intermediaries in the trade of works of art
the Monégasque private sector needs to And it’s not just in Monaco that professionals - persons who store or trade works of art or
improve. “The number of suspicious transaction are uncomfortable with these obligations. The act as intermediaries in the trade of works
reports (STRs) from the banking sector can be DGCCRF, one of the supervisory authorities of art when this is carried out in free ports,
considered quite satisfactory, although the in the fight against money laundering, when the value of the transaction or a series
large volume of so-called “coverage” reports, surveyed operators in the real estate, of related transactions is €10,000
as well as the excessively long transmission business domiciliation and luxury sectors - pawnbrokers and their commission agents
times, raise questions about the quality of the (watchmakers, jewellers, precious metal - multi-family offices
information provided. Designated non-financial dealers, goldsmiths etc) in 2020 in order to - accountants
businesses and professions (DNFBPs) have an verify that the professions are respecting their - crowdfunding advisors and intermediaries
inferior understanding of AML/CFT risks and obligations in this area – and more than 60% - sports agents
a weaker culture of compliance. The number of the establishments inspected presented - legal entities holding authorisation to carry
of STRs from casinos and jewellers remains anomalies! out a token offering
limited, even though these sectors are of - any person who, as a usual profession,
particular importance in the Principality,” Who are the professionals subject to the either acts as a counterparty or acts as an
according to the anti-money laundering body anti-money laundering law? intermediary, with a view to the acquisition
of the Council of Europe. - credit institutions including branches or sale of virtual financial assets
This is why the AMSF has worked hard to established in the territory of the Principality, - providers of custody services on behalf of
support professionals, with webinars, training whose head office is located abroad, and third parties of digital assets or access to
sessions, guidelines, sectoral and thematic financing companies digital assets
practical guides – and the message is clear: do - payment institutions and electronic money - the sale or rental of antiques, precious
not hesitate to make a suspicious transaction institutions materials, precious stones, jewellery,
report. “Not being able to identify a beneficial - insurance companies watches, leather goods, land, air or sea
owner means taking the risk of transacting with - persons carrying out, on a regular basis, vehicles and other objects of high value
a person under sanction, with the snowball operations of creation, management and - notaries, bailiffs and lawyers.

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